[arin-ppml] anti- flip Draft 2014-2

Rudolph Daniel rudi.daniel at gmail.com
Fri Mar 7 12:03:32 EST 2014


I can see the logic of supporting "3". I am going inclined to agree with
David. We have to promote accuracy in whois as a policy priority.

I support No. 3

Rudi Daniel
(information technologist)
784 430 9235
On Mar 5, 2014 10:02 PM, <arin-ppml-request at arin.net> wrote:

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> Today's Topics:
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>    1. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip       Language
>       (David Huberman)
>    2. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip       Language
>       (Spam Auditor)
>    3. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip       Language
>       (Bill Darte)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Wed, 5 Mar 2014 21:17:58 +0000
> From: David Huberman <David.Huberman at microsoft.com>
> To: Bill Darte <billdarte at gmail.com>, "arin-ppml at arin.net"
>         <arin-ppml at arin.net>, Owen DeLong <owen at delong.com>
> Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4
>         Anti-Flip       Language
> Message-ID:
>         <
> 87b03e32ad2743559958047e94c94044 at DM2PR03MB398.namprd03.prod.outlook.com>
>
> Content-Type: text/plain; charset="us-ascii"
>
> As the author of this proposal, and having encountered the real-world
> consequences of existing 8.4 anti-flip language, I support #3 as the
> cleanest, simplest approach that best promotes Whois accuracy.
>
>
>
> ARIN is a registry, not a regulator.  Let's write policy that promotes
> accuracy in Whois, please.
>
>
>
> David R Huberman
> Microsoft Corporation
> Senior IT/OPS Program Manager (GFS)
> ________________________________
> From: Bill Darte <billdarte at gmail.com>
> Sent: Wednesday, March 5, 2014 7:00 AM
> To: arin-ppml at arin.net; David Huberman; Owen DeLong
> Subject: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip Language
>
> On Feb. 21 I sent the message (far below) to PPML asking the community to
> support one of 3 alternatives or propose new language which makes one or
> the other better, or a completely new wording which they believe
> accomplishes the goal of producing policy language that is needed,
> technically sound and improves existing policy in the 8.4 Inter-RIR
> transfer realm.
>
>
> Summary of feedback so far:
> 2 persons supporting #2 with the removal of "and its subsidiaries".  There
> was some support for the extended language of "and its subsidiaries having
> been operational for a minimum of xx months" in order to mitigate the
> rinse-repeat abuse that might accrue through new shell subsidiaries.
>
>
> There was some support for the alternative language expressed in #3 at the
> PPC in Atlanta and at the ARIN AC meeting on Feb 20.  This language simply
> restricts the transfer of the block having been received...which would
> allow other existing blocks or components to be transferred.  One view
> against #3 was expressed as "An org that currently has a /8 can obtain the
> resources it needs and sell off the /8 out of region a few chunks at a time
> by backfilling with new space from the ARIN region.". A rejoinder to this
> was expressed pointing out that other existing language in 8.4
> states...."Source entities within the ARIN region will not be eligible to
> receive any further IPv4 address allocations or assignments from ARIN for a
> period of 12 months after a transfer approval, or until the exhaustion of
> ARIN's IPv4 space, whichever occurs first."
> <<< end summary >>>>
>
>
>
>
> It is important that I receive a significant measure of support FOR or
> AGAINST continuing to work on this Draft and before the ARIN AC meeting on
> Mar 20, I would like to have better language to propose if we are to make
> this Draft a Recommended Draft prior to the April PPM in Chicago.
>
>
> I would be grateful for your feedback as early as possible.
>
>
> bd
>
>
> <<<<<<<<< earlier email sent to PPML on Feb 21 >>>>>>>>>>>>>>>
> At the Advisory Council's meeting of Feb 20, discussion about Draft Policy
> 2014-2 concluded that there is a real issue with transfer restrictions of
> address blocks between RIR jurisdictions for organizations having received
> a different block of addresses from ARIN within the last 12 months (per
> existing policy).
>
>
> The current Draft Policy language is as follows with only the last
> sentence being added from what is current ARIN policy:
> "Source entities within the ARIN region must not have received a transfer,
> allocation, or assignment of IPv4 number resources from ARIN for the 12
> months prior to the approval of a transfer request. This restriction does
> not include M&A transfers. Restrictions related to recent receipt of blocks
> shall not apply to inter-RIR transfers within the same organization and its
> subsidiaries."
>
>
> The last sentence of this language was added to mitigate the problems
> related by the author in the problem statement and from experience. The
> author supported this change, however, some concern has been expressed on
> the PPML and within the AC about the possibility of 'rinse and repeat'
> abuse associated with the ease of establishing new subsidiaries and using
> those transfers to get around the restrictions of the existing transfer
> policy.
>
>
> Three alternatives were primarily discussed and I wish to elicit feedback
> from the community relative to each.
>
>
> 1. Use the existing last sentence as is and ask ARIN staff to be
> particularly watchful for seeming abuse and to bring such back to the
> community through regular Policy Experience Reports.  There was discussion
> about this option suggesting that by the time abuse was recognized and
> reported, and given limited existing free pool stocks and the extended
> policy development cycle....this option may be moot.
>
>
> 2. Remove the clause 'and its subsidiaries' or modify it in such a way as
> to mitigate the risk of a laundering of addresses through fraudulent
> transfers, but this may still potentially limit the utility to
> organizations who may have complex organizational structures in use
> internationally.
>
>
> 3. Take an alternative tack and simply restrict transfers on a per-block
> rather than a per-organization basis. e.g. 'No block acquired within the
> past 24 months would be eligible for transfer.' (The time frame is of
> course an arbitrary number at this point.)
>
>
> If you believe this Draft Policy is improved most significantly by one of
> the above alternatives, or through another alternative you can pose....I,
> and the community would benefit from your input. Thanks,
>
>
> Bill Darte
> Policy Shepherd for 2014-2 and
> Advisory Council member
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>
> Message: 2
> Date: Wed, 05 Mar 2014 17:54:34 -0800
> From: Spam Auditor <spamauditor at linuxmagic.com>
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4
>         Anti-Flip       Language
> Message-ID: <5317D55A.1030302 at linuxmagic.com>
> Content-Type: text/plain; charset=ISO-8859-1; format=flowed
>
> On 14-03-05 01:17 PM, David Huberman wrote:
> > As the author of this proposal, and having encountered the real-world
> > consequences of existing 8.4 anti-flip language, I support #3 as the
> > cleanest, simplest approach that best promotes Whois accuracy.
> >
> > ARIN is a registry, not a regulator.  Let's write policy that promotes
> > accuracy in Whois, please.
> >
> > *David R Huberman*
> > Microsoft Corporation
> > Senior IT/OPS Program Manager (GFS)
>
> Here, Here...
>
> However, even though it isn't a regulator, there should be enforcement
> considerations, especially when IP Space is granted and used for
> purposes contrary to the application..
>
>
>
>
> ------------------------------
>
> Message: 3
> Date: Wed, 5 Mar 2014 19:58:50 -0600
> From: Bill Darte <billdarte at gmail.com>
> To: Spam Auditor <spamauditor at linuxmagic.com>
> Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4
>         Anti-Flip       Language
> Message-ID:
>         <CAMApp35hhh=
> djm_6j0mh-F2MNxWt4GMGLz771JHDUg+zYs0cag at mail.gmail.com>
> Content-Type: text/plain; charset="iso-8859-1"
>
> Spam Auditor....
> Are you FOR or AGAINST the proposal in general....and does your 'Hear,
> Here' include David's support for option #3?
> Thanks,
> bd
>
>
> On Wed, Mar 5, 2014 at 7:54 PM, Spam Auditor <spamauditor at linuxmagic.com
> >wrote:
>
> > On 14-03-05 01:17 PM, David Huberman wrote:
> >
> >> As the author of this proposal, and having encountered the real-world
> >> consequences of existing 8.4 anti-flip language, I support #3 as the
> >> cleanest, simplest approach that best promotes Whois accuracy.
> >>
> >> ARIN is a registry, not a regulator.  Let's write policy that promotes
> >> accuracy in Whois, please.
> >>
> >> *David R Huberman*
> >> Microsoft Corporation
> >> Senior IT/OPS Program Manager (GFS)
> >>
> >
> > Here, Here...
> >
> > However, even though it isn't a regulator, there should be enforcement
> > considerations, especially when IP Space is granted and used for purposes
> > contrary to the application..
> >
> >
> > _______________________________________________
> > PPML
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